https://www.taxtmi.com/caselaws?id=763468 The ITAT Mumbai allowed the assessee's appeals on multiple grounds. The tribunal permitted deduction under section 37(1) for employee stock option scheme reimbursements to parent company, finding the expenditure was incurred for business purposes on cost-to-cost basis without markup. Software license fees for short-term subscriptions were treated as revenue expenditure rather than capital, as these did not create enduring assets. The tribunal upheld section 10A deduction for software export unit, rejecting AO's splitting argument and confirming eligibility based on foreign exchange earnings. Forward contract losses were classified as business losses rather than speculation, as the assessee was hedging export risks, not trading commodities. en-us Wed, 30 Oct 2024 00:00:00 +0530 Thu, 19 Dec 2024 10:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763468 The ITAT Mumbai allowed the assessee's appeals on multiple grounds. The tribunal permitted deduction under section 37(1) for employee stock option scheme reimbursements to parent company, finding the expenditure was incurred for business purposes on cost-to-cost basis without markup. Software license fees for short-term subscriptions were treated as revenue expenditure rather than capital, as these did not create enduring assets. The tribunal upheld section 10A deduction for software export unit, rejecting AO's splitting argument and confirming eligibility based on foreign exchange earnings. Forward contract losses were classified as business losses rather than speculation, as the assessee was hedging export risks, not trading commodities. Case-Laws Income Tax Wed, 30 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763468